Those concerned about the $32 billion firearm industry--gun owners, investors, whatever--should shift their attention from Capital Hill to courtrooms around the country. Potentially damaging gun-control measures seem more likely to come from the country's justices than from its 535 lawmakers.

Two federal appeals courts last week reviewed the legality behind concealed carry laws. In Denver, the court decided that concealed-carry firearms aren't protected by the Second Amendment. A thousand miles away in Chicago, the court reached a different decision. It declined to reconsider a ruling that found that state's ban on concealed carry unconstitutional.

These two courts aren't the first to mull this issue. A New York federal appeals court last November upheld a state law that required concealed-carry applicants to prove "proper cause" to obtain concealed-carry licenses. Looking ahead, appeals courts in California and Virginia are set to review the issue.

Concealed carry laws have been on the rise for the greater part of three decades. They could very well soon stretch nationwide, if Illinois completes its about-face on concealed carry. Not too surprisingly, it's most prevalent in red states, especially so in Georgia, Utah and Florida; in the Peach State, for example, more than 12% of adults 20 and older have an active permit. All told, more than 8 million Americans have one. And not only has the number of licensing states increased in the past ten years (in 2002, seven states including Illinois banned concealed carry), but more and more states are recognizing others' permits, making it practical to become licensed and purchase a weapon.

Gun companies moved quickly to take advantage of this boom, as well as a growing comfort with firearms after anti-gun campaigns of the 1990s. Today, concealed carry weapons--small, compact pistols and revolvers--are one of the most crucial parts of the firearm business. Both Sturm, Ruger and Smith & Wesson sell far more handguns than long-guns; Forbes last year estimated that Ruger's ultra-popular Lightweight Compact Revolver and Lightweight Compact Pistol make up about 17% of the company's sales alone ($55 million). These small firearms are often marketed to women, a particularly fast-growing segment of firearm owners. Ruger even makes LCRs and LCPs models with pink grips.

This is all why the courtroom battle over concealed carry matters much more than whether Congress actually creates legislation that limits semi-automatic rifles (the type of weapon used in the Sandy Hook Elementary massacre). Fact is, gun rights lawmakers are already posturing to declaw any gun law that comes through Congress. Senate Majority Leader Harry Reid (D-Nevada) is set to stand tall in the Senate, and the Republican-dominated House of Representatives would prove hard to sway toward sweeping legislation. It seems pretty safe to assume that we'll continue to be able to stock a large arsenal from a simple stop at Wal-Mart, Dick's Sporting Goods or Cabela's.

A shopping trip that could quite possibly not include any small handguns. What's next in the courts? Contradictory appeal decisions would raise the likelihood that the matter would reach the Supreme Court. It would mark the first time that the nation's highest court would weigh gun control arguments since two blockbuster cases in 2008 and 2010. The earlier case, District of Columbia v. Heller, upheld many 19th century prohibitions on concealed weapons, but also acknowledged that the Second Amendment protects a right to own guns. Then, the court took matters a step forward two years later: In McDonald v. Chicago, it established that state and local laws should also recognize the right to own firearms.

Significantly, McDonald v. Chicago said only that there's a right to keep handguns in the home for self-defense, but not anything about what types of gun control laws violate the Second Amendment. Stopping short there has set up today's brewing disagreement over concealed carry.

Reach Abram Brown at abrown@forbes.com.

(ADDENDUM: Sorry, folks, but Adam Lanza, the Sandy Hook killer, did in fact use the AR-15 rifle. Here's a link directly to the Connecticut State Police debunking that theory. And if Lanza did use handguns, there's a good chance the weapons may have been models designed to attract concealed carry laws, making the odds of concealed carry bans more likely.)